20 January 2021

Clipperton & Lloyd v HMRC; (FTT)

The First-tier Tribunal released its Decision in Sharon Clipperton & Steven Lloyd v The Commissioners for Her Majesty’s Revenue and Customs.

Laura Poots, led by Aparna Nathan (now QC), acted for HMRC in this case concerning a scheme designed to enable companies to pay funds to shareholders (which would otherwise have been paid as a dividend or distribution) in a tax-free way, by taking advantage of the settlements legislation.  The First-tier Tribunal found that the payment was taxable as a distribution in the hands of the shareholders, and the taxpayer’s appeal was dismissed.

To see the approved decision, click here.